Last week, HRC submitted a public comment in response to the Administration on Community Living's (ACL) proposed revisions to the 2017 National Survey of Older Americans Act Participants (NSOAAP). ACL, an office within the Department of Health and Human Services had initially published the 2017 survey in March with a single change -- the elimination of data collection efforts directed at LGBTQ seniors.

Following an outpouring of protest from LGBTQ people and allies, including over 4,800 public comments from HRC members and supporters, ACL published a revised survey in June re-incorporating sexual orientation within the 2017 survey. However, the revised survey still excludes transgender and gender nonconforming respondents from the survey. In HRC's comments submitted yesterday we urged ACL to include specific information gathering regarding transgender status and gender identity. The current gender question included in the survey provides respondents with the following response choices to describe their gender: “male”, “female”, “refused”, and “don’t know.” This question fails to capture data regarding the gender identity of respondents and subsequently does not identify transgender elders in survey analysis and reporting. It also fails to provide elders with the opportunity to self-identify – a general best practice.

Members of Congress on both sides of the aisle have also urged ACL to take affirmative steps to ensure that transgender seniors are included within the survey. Yesterday, 76 members of Congress signed a letter, led by Representative Ted Deutch (D-FL) who is the Chair of the Aging Task Force of the LGBT Equality Caucus, highlighting the barriers to successful aging faced by transgender seniors and the role federal data collection can play to bridge these disparities.

The continued exclusion of transgender older Americans from this critical survey continues to ignore known health and service disparities, and signals federal indifference toward and neglect of the experiences and needs of this already vulnerable population. The NSOAAP purports to directly assess several areas that speak directly to barriers identified by the landmark 2010 Institute of Medicine Report on LGBTQ health (now the National Academy of Sciences) as particularly vulnerable areas for transgender people including an increased need for caregiver support, case management, nutrition and homemaker support, and transportation. ACL’s decision to exclude transgender respondents from the 2017 survey ignores these critical findings and unnecessarily forfeits a valuable research opportunity as described by the National Academy.

Although HRC appreciates the steps that ACL has taken to remedy the harmful revisions made to the 2017 NSOAAP in March relating to sexual orientation, we must unite to urge HHS to recognize that these changes are far from complete. ACL and the federal government must take proactive steps to incorporate transgender older adults within this critical survey. Comprehensive, uniform data collection is an essential tool to ensure that all seniors have equal access to the federal programs and services to which they're entitled. To read HRC's comments, click here.